- 4 - transfer from the Retirement System to the Pension System was effective retroactively to the first of that month; i.e., to November 1, 1990.3 The Retirement System is a qualified defined benefit plan under section 401(a). The Retirement System requires mandatory nondeductible employee contributions. The Pension System is also a qualified defined benefit plan under section 401(a) but generally does not require mandatory nondeductible employee contributions. The State of Maryland contributes to both the Retirement System and the Pension System on behalf of the members of those systems. The trusts maintained as part of the Retirement System and the Pension System are both exempt from taxation under section 501(a). In 1990, petitioner received a Transfer Refund distribution (the Transfer Refund) in the amount of $216,616.26 on account of his election to transfer from the Retirement System to the Pension System. The $216,616.26 Transfer Refund consisted of $32,151.31 in previously taxed contributions made by petitioner and $184,464.95 of earnings.4 The earnings represented interest, computed based on an annually compounded rate of approximately 3 For a discussion of the Retirement System and the Pension System, see generally Hylton v. Commissioner, T.C. Memo. 1995-27; Hoppe v. Commissioner, T.C. Memo. 1994-635; Hamilton v. Commissioner, T.C. Memo. 1994-633; Maryland State Teachers Association v. Hughes, 594 F. Supp. 1353, 1357-1358 (D. Md. 1984). 4 So stipulated.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011